I have a client that owes approximately $536 in Federal tax liability, and has not yet filed their return.  With respect to the failure to file and failure to pay penalties, they should qualify for a first time penalty abatement, as they have a clean record.  In addition, I know that there are letter templates out there (AICPA) for claiming COVID-19 as reasonable cause for failure to file timely.  Rather than wait until receipt of the IRS penalty notice, the client would like to attach their reasonable cause for penalty abatement statement to their return for paper filing.  Would this create undue confusion for the IRS, or is it an acceptable action?